Legal Opinion

Daugherty v. Commissioner

United States Tax Court

Decided April 15, 1982No. Docket No. 21161-80Published

Ps, who operated a proprietorship engaged in the sale of real estate to customers in the ordinary course of their business, purchased in 1968 for $ 11,000 certain acres of unimproved waterfront land adjacent to Janes Island State Park in Maryland. From 1968 through 1972 they platted, subdivided, and preliminarily developed the property. In 1973, Ps received notice from the State of Maryland that it was interested in acquiring the property by condemnation.

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Ps, who operated a proprietorship engaged in the sale of real estate to customers in the ordinary course of their business, purchased in 1968 for $ 11,000 certain acres of unimproved waterfront land adjacent to Janes Island State Park in Maryland. From 1968 through 1972 they platted, subdivided, and preliminarily developed the property. In 1973, Ps received notice from the State of Maryland that it was interested in acquiring the property by condemnation. In 1974, condemnation proceedings were begun, which culminated in April 1975 in a settlement whereby Ps received $ 165,000. On their 1976…

1Opinion of the Court

William B. Daugherty and Charlotte G. Daugherty, Petitioners v. Commissioner of Internal Revenue, Respondent

Daugherty v. Commissioner

Docket No. 21161-80

United States Tax Court

78 T.C. 623; 1982 U.S. Tax Ct. LEXIS 110; 78 T.C. No. 43;

April 15, 1982, Filed

Decision will be entered for the respondent.

Ps, who operated a proprietorship engaged in the sale of real estate to customers in the ordinary course of their business, purchased in 1968 for $ 11,000 certain acres of unimproved waterfront land adjacent to Janes Island State Park in Maryland. From 1968 through 1972 they platted, subdivided, and…

Also in this document: Concurrence · Fay; Concurrence · Goffe.

2Cases cited44 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  3. Lyeth v. HoeySupreme Court of the United States · 1938
  4. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  5. Malat v. RiddellSupreme Court of the United States · 1966

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